Newwwton, Inc. (“Newwwton”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our website located at www.newwwton.com (the “Site”) and related software, services, features, communication and content. A user of the Services or Site, whether with a registered account or a user just browsing the Site or communicating with representatives of Newwwton, is hereinafter referred to as a “User,” or collectively, the “Users”.

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at: www.newwwton.com/legal/terms-of-use/. Capitalized terms used herein but not otherwise defined will have the definitions provided in the Terms and Conditions. As used in this policy, the terms “using” and “processing” information include using Cookies (defined below) on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among affiliates or partners we establish.

We will not rent, sell, share your personal information except in accordance with this policy.

INFORMATION COLLECTION AND USE

Our primary goals in collecting, using and processing information via our website are to provide Users with access to and use of our services, to improve and further develop our services and to enable users to enjoy and easily navigate the Site. We will not share your information with marketers. However, we reserve the right to sell information in a sale of the corporation.

CONFIDENTIALITY

At Newwwton, we understand that our clients sometimes provide us with confidential business documents. We will protect the confidentiality of your documents and only share them with the necessary Newwwton personnel to complete the assignment, unless agreed upon otherwise. For any materials sent to or created by Newwwton as a part of a service agreement, we will explicitly ask for verbal or written permission before we use these materials in our own marketing efforts.

PERSONALLY IDENTIFIABLE INFORMATION

In the course of using Newwwton we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you; personally identifiable information may include, but is not limited to, your name, company name, email address, postal address, work experience and interests, and phone number (”Information“).

If you use the website to make or receive payments, we will also collect certain Personal Information such as credit card information, PayPal or other financial account information, and billing address.

We may collect additional Personal Information to validate your identity, such as your date of birth, place of birth or taxpayer identification number. We may request documents to verify this information, such as a copy of your government-issued identification or photo, and we may authenticate it against third party databases or request a credit report.

We use your Personal Information mainly to provide our service, complete your transactions, and administer your inquiries.

When you send a service request to Newwwton, you will be opting-in to receive Newwwton emails, newsletters, marketing and/or promotional materials. We will also use your Personal Information to send this content to you. If you decide at any time that you no longer wish to receive such communications from us, you can opt-out or customize the type of messages you receive from Newwwton by clicking on the unsubscribe link included at the bottom of Newwwton emails, or by emailing us at support@newwwton.com. Please note that any such opt-out applies solely to marketing related emails. Newwwton will still need to communicate with you via email with regarding non-marketing related matters related to the Site and you acknowledge and agree that Newwwton has the right to do so.

NEWWWTON' USE OF PERSONAL INFORMATION

Newwwton uses Personal Information for the following general purposes:

• To provide our services and the website,
• For billing, identification and authentication, and fraud prevention,
• To analyze Site usage and improve our products and the website,
• To contact you and deliver administrative notices and communications relevant to your use our products and services,
• For internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity,
• To enforce our Terms and Conditions, and as otherwise set forth in the Privacy Policy.
• We may employ third party companies and individuals to facilitate our website, to provide the services of the website on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of the Siteʼs features), to assist us in analyzing how our Site is used or to provide other business services (e.g., without limitation, debt collection, accounting, legal, auditing and banking). These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Although we ensure that our third party agents (“Agents”) receiving your information are bound by confidentiality obligations. Newwwton is not responsible for and shall not be liable for any issues that may arise regarding the Privacy Policies of any of its agents, affiliates, advertiser and/or any other third parties. By using this website, you do hereby agree to hold Newwwton indemnify, defend and hold harmless Newwwton from any claims and/or damages that may arise from the actions of any of Newwwtonʼ Agents, affiliates and/or advertisers.

Two things drive Newwwtonʼ decisions regarding the use of information collected from users: 1) improving user experience by offering personalized services, content and advertising, and 2) market research.

Ads are a standard part of user experience on the Internet, and Newwwton believes that targeted advertising enhances this experience. Newwwton may use Cookies (defined below) and other technologies and Personal Information to place ads where they believe interested parties will see them. In addition to banner ads, Newwwton may advertise products, companies and events that we think might interest you through the email address you provide.

Newwwton may analyze Personal Information and Web Navigational Data based on your interests and may use the analysis from this information in a way that does not contain any Personal Information (“Market Research”) in order to:

• Market the Website
• Improve the likelihood of a sale to a new Users
• Increase the likelihood that a User's experience with the Site is relevant to its interests
• Newwwton uses data at the individual level to sell products and services to Users who express an interest in these products and services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Research.

If you would like more information about our policy, or to opt out, please review our Terms and Conditions, available at Newwwton; by accepting these Terms and Conditions you are indicating your consent to be contacted at the phone number you have provided for the purposes described above.

CALIFORNIA PRIVACY DISCLOSURES

Newwwton does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties cannot collect any other personally identifiable information from Newwwton unless you provide it to them directly.

INFORMATION SHARING

When you submit information to Newwwton, it is collected, processed and maintained solely by us or by third party Agents who are bound by confidentiality obligations. We may share or otherwise use aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information. Newwwton reserves the right to disclose Personal Information from both private and public areas of this website at our discretion, if required by law or if we are given reason to believe, in our sole discretion, that such disclosure is necessary in order to prevent harm to our Site or our Users or to protect the rights of our Users, the general public, or Newwwton, to comply with a judicial proceeding, court order or legal process.

LOG DATA

When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data ”). This Log Data may include information such as your computerʼs Internet Protocol (‘IP”) address, browser type, browser software version or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Siteʼs functionality and user-friendliness, to better tailor it to our visitorsʼ needs, and to detect suspicious activity. These third party service providers have their own privacy policies addressing how they use such information. We do not treat Log Data as Personal Information, but we may use it in association with Personal Information, and we may aggregate, analyze and evaluate such Log Data for the same purposes as stated above regarding other Non-Identifying Information.

COOKIES

Like many websites, we use ”Cookies”, a small data file that we transfer to your computerʼs hard disk for record-keeping purposes, to collect information. We use Cookies for two purposes. First, we utilize persistent Cookies to save your registration ID and login password for future logins to the Site and to track your compliance with our marketplace policies. Second, we utilize session ID Cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by Newwwton Users and web traffic routing on the Site. Unlike persistent Cookies, session Cookies are deleted from your computer when you log off from the Site and then close your browser. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you may not be able to use all portions of the Site.

NO PHI

While Newwwton takes security and privacy very seriously, Newwwton is not a HIPAA Business Associate and Newwwton is not HIPAA-compliant and should not be used to store any protected health information (“PHI”). You agree that you will not upload or store any documents containing PHI. To do so would be a violation of our Terms and Conditions.

PHISHING

Identity theft and the practice currently known as ”phishing” are of great concern to Newwwton. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. We suggest advise you not to respond to and to promptly report any email or telephone communication purporting to be from Newwwton in which such information is collected. For more information about phishing, visit the Federal Trade Commissionʼs website.

FEEDBACK

We collect feedback from users about their experience with other users of the Site. Please note that any Admin feedback provided will be publicly viewable via the Site.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

Newwwton cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Newwwton or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

CHANGING OR DELETING YOUR INFORMATION

All users may review, update, correct or delete the Personal Information in their Client profile by contacting us. If you would like us to delete your account in our system, please contact us at support@newwwton.com. We may retain an archived copy of your records as required by law or for legitimate business purposes.

SECURITY

Newwwton is very concerned with safeguarding your Personal Information. The security of such Personal Information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information (such as credit card number or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems.

INTERNATIONAL TRANSFER

Your information may be transferred outside of the jurisdiction in which you reside and may be stored or otherwise maintained on — information systems and devices located in jurisdictions where the privacy laws differ from and in some cases may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Newwwton transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer and your acknowledgement and acceptance of the fact that the treatment of such information will governed by the applicable laws of the United States.

LINKS TO OTHER SITES

Our Site contains links to other websites. If you choose to click on a third party link, you will be directed to that third partyʼs website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own Cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

CHILDREN

This Site is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@newwwton.com. If we become aware that a child under 13 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at legal@newwwton.com.